On October 31st, NYSEIA and the Coalition for Community Solar Access (CCSA) (referred to as “Solar + Storage Parties” or “SSP”) filed comments under case 15-E-0302  in response to questions posed by the New York Public Service Commission (PSC) regarding utility ownership of renewable generation (UOG).

The SSP oppose utility-owned generation for several reasons, including:

• Increased costs to ratepayers: Utilities have a track record of cost overruns that are borne by ratepayers, with UOG– the capital cost of risk and performance risk are transferred to ratepayers as well

• Broad utility ownership slows progress towards clean energy goals: There is no demonstrated timeline advantage to UOG, in fact it would significantly diminish private sector participation when the private sector has capacity to meet Climate Act requirements. UOG also diverts the utilities’ focus, delaying interconnection and congesting networks.

• Market Distortion: Competition between UOG and private projects would be ineffective, as utilities have significant structural advantages unavailable to third parties. Simultaneously, costs in different service territories would increase at different rates, and there would be challenges with “non-market” energy storage resources.

The SSP urge the Commission to limit broad utility ownership of renewables and energy storage. Instead, the SSP provides recommendations on permitting reform, interconnection reform, and rate design improvements, including: 

• Improving the accuracy of the Value of Distributed Energy Resources (VDER) tariff

• Advancing permitting improvements for utility-scale and distributed resources

• Transparency in the interconnection process

• Flexible interconnection, enabling self-performance of distribution upgrades, and proactive planning for distribution and transmission

• Performance-based ratemaking

If the Commission were to consider expanding UOG, the SSP recommend the Commission narrowly limit the program’s scope, establish guardrails to protect ratepayers, and limit market distortion. Some actions would include:

• Requiring that utility shareholders bear 100% of cost overruns

• Appointing a shareholder-funded UOG project monitor

• Requiring that shareholders bear 100% of development risk by prohibiting utilities from adding UOG to their rate base before achieving commercial operation

• Creating a mechanism to ensure that utility shareholders bear 100% of performance risk for ratepayer-funded projects

• Limiting the amount or type of projects that can be developed by the utilities

Click “READ MORE” for the full comments.